Introduction

This statement is made pursuant to section 54 of the UK Modern Slavery Act 2015 and the Australian Modern Slavery Act 2018. It sets out the steps taken by the Operative group of companies during the financial year ending 31 December 2026 to ensure that modern slavery and human trafficking are not taking place within our business or supply chains.

This statement has been approved by the Board of Directors of Operative and will be reviewed and updated annually.

About Operative

Operative (comprising SintecMedia, NYC, Inc., SintecMedia Ltd., and their affiliates and subsidiaries, collectively “Operative”) is a global software company providing revenue management solutions and services to converged media companies worldwide. We operate primarily in low-risk jurisdictions and do not manufacture or sell physical goods.

Our workforce is predominantly professional and knowledge-based, operating across office, home, and hybrid environments. We have operations and employees in the following regions:

• United States
• United Kingdom
• Australia
• Canada
• Brazil
• India
• Israel
• Romania
• Netherlands

Our Commitment

Operative has a zero-tolerance approach to modern slavery and human trafficking in all its forms, including forced labour, debt bondage, child labour, servitude, and human trafficking. We are committed to acting ethically and with integrity across all our business activities and to implementing effective systems and controls to ensure that modern slavery does not occur anywhere in our organisation or supply chains.

We expect the same standards from all suppliers, contractors, and business partners who work with us or on our behalf.

Polices and Governance

Operative maintains a suite of policies that underpin our commitment to preventing modern slavery, including:

• Anti-Slavery Policy – sets out our zero-tolerance approach and the obligations of all colleagues and business partners
• Code of Ethics & Conflict of Interest Policy – establishes the ethical standards expected of all employees
• Diversity, Equality & Inclusion Policy – promotes fair and ethical treatment of all individuals
• Whistleblowing / Reporting Policy – provides safe and confidential channels for raising concerns

All policies are approved by senior management, communicated to employees upon joining Operative, and reviewed periodically. Every new employee is required to read, acknowledge, and sign the Anti-Slavery Policy as part of their onboarding.

Risk Assessment and Due Diligence 

Following a review of our operations and supply chain, we consider the overall risk of modern slavery within our business to be low. Operative is a technology and services company and does not operate in manufacturing, agriculture, or other sectors generally considered higher risk. However, we remain vigilant and maintain oversight of the following areas: 

Office and Facilities Services: Cleaning, catering, and other facilities services are typically managed by our property managers. Where we have the ability to influence contractual terms, we seek to include provisions requiring appropriate measures to address modern slavery risks within their operations and those of their subcontractors. 

Third-Party Contractors and Staffing Agencies: Where we engage workers through third-party providers, we seek assurances that such providers comply with applicable anti-slavery and labour laws and, where appropriate, our Anti-Slavery Policy. Service agreements may include modern slavery and labour compliance provisions depending on the nature of the engagement and the parties’ contracting arrangements. 

Procurement and Supply Chain: We take a risk-based approach to supplier management. Where appropriate, we seek to include human rights and labour compliance provisions in supplier agreements and apply enhanced scrutiny to suppliers operating in higher-risk jurisdictions. New and existing suppliers may be assessed on a risk-proportionate basis. 

Where potential risks are identified, we may take appropriate action, including seeking remediation, increasing monitoring, or, where appropriate, terminating the relationship.

Awareness

All Operative employees are required to read and sign our Anti-Slavery Policy upon joining and on a recurring annual policy update basis. Our policy covers: 

• What modern slavery and human trafficking are and how to recognise warning signs 
• Operative’s zero-tolerance approach and relevant policies 
• How to report concerns safely and confidentially

Reporting Concerns

We encourage openness and will support anyone who raises genuine concerns in good faith. If any employee, contractor, or third party becomes aware of or suspects that modern slavery is taking place – whether within Operative or its supply chain – they should report it immediately through one of the following channels: 

• Their line manager or local HR representative 
• The Global Head of HR 
• The Legal Team 
• Anonymously via our internal reporting platform 

No individual who raises a concern in good faith will suffer any detriment or retaliation as a result of doing so.

Key Performance Indicators 

To monitor the effectiveness of our approach, Operative tracks the following indicators on an annual basis:

• Percentage of employees reading and signing our Anti-Slavery Policy 
• Number of modern slavery concerns reported (via any channel) and outcomes 

Performance against these indicators is reviewed annually by senior management and informs updates to this statement and our underlying policies.

Approval and Sign-off 

This statement has been approved by the Board of Directors of Operative and is signed on their behalf by: 

Hanan Aharoni
Chief Financial and Operations Officer
1st September 2026